The Facility’s loss of authorization was due to consecutive audits that failed to meet MCS. The issues that led to loss of authorization are Partial Access Denied (to documentation and facility premises), Involuntary Labor (restrict access to dormitory & withholding of employee identification), and Transparency (discrepancies between documents and/or employee interviews). This reinstatement requires:

A qualified audit that meets Disney’s Minimum Compliance Standard (MCS).

A Facility Reinstatement Form approved by the Disney Business Unit Vice President. Please verify that the name and title of the person signing the form are clearly written. Alex: For the reinstatement form attached, please ask licensee to check off in Section B; and then ask Kermid to approve (email approve will be fine);

Supporting documents in English that demonstrate the additional measures taken by the Facility to prevent recurrence of the noncompliance(s) that led to loss of authorization. Alex: all supporting documents should be read friendly, we can discuss on it further and share some guidelines.

We added highlights to the required document for the licensee/factory to use as a guide for naming documents. Please match the documents to the highlighted name. Though this is not required, it will help improve efficiency

Supporting documents may include but are not limited to:

Statement from the facility confirming the prohibition of the practices which led to loss of authorization. Please include measures the facility has taken to prevent such issues from arising again since losing authorization.

Letter or email from facility management confirming their understanding that they must provide auditors with full access to workers for confidential interviews, required documents, and facility premises including dormitories.

Factory's written policies and procedures on accepting audits and record maintenance, including identification of personnel responsible for the records and procedures if the primary person is not available to provide access to the records

Factory's written policies and procedures on involuntary labor (including issues such as voluntary overtime, freedom of movement, and withholding of personal documents such as passports, IDs, etc.).

CAP addressing the transparency/coached worker/record-keeping discrepancy non-compliances that led to loss of authorization.

Factory's written policies and procedures on recording and maintenance of wage and hour related records. Should include:

procedures for how workers should record working hours

how wage and hour records are maintained

how facility ensures accuracy of their records (ex. Regular internal audits)

steps taken if discrepancies are identified

Identification of personnel or department(s) responsible for enforcing and implementing the policies and procedures regarding the issues that led to loss of authorization

Evidence of management and supervisor training of the policies and procedures relating to the issues that led to loss of authorization.

· External training documents